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DAC 6 and tax disclosure

Practical guidance and support on tax disclosure around the world including, DAC 6 and the OECD’s mandatory disclosure regime.

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DAC 6 and OECD disclosure in brief

An overview of the EU and OECD Mandatory Disclosure Regimes in the context of UK reporting. This 20-min webinar covers what is DAC 6; who it affects; what types of arrangements will be caught; what the reporting requirements are and potential penalties.
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ICAEW's Tax Faculty provides expert support and insights into the latest developments in the UK's tax system.

Features and articles

EU Council reaches agreement on exchange of information for crypto assets and advance tax rulings for high-net-worth individuals
  • Article
  • 26 May 2023
The unanimous agreement paves the way for greater co-operation between member states to reduce opportunities for tax avoidance and tax fraud using crypto assets, by amending the directive on administrative co-operation in the area of taxation (DAC).
Tax news in brief 19 April 2023
  • Article
  • 19 Apr 2023
Highlights from the broader tax news for the week ending 19 April 2023, including: closure of online VAT return; PAYE direct debits; TRS reporting requirements; interest rate increase for discounted gift trusts; NMW campaign; Finance Bill amendment for R&D; closure of the DAC6 reporting service; and Tax Administration and Maintenance Day.
Mandatory disclosure rules replace DAC 6 in the UK
  • Article
  • 24 Jan 2023
Cross-border tax avoidance arrangement disclosure rules devised by the OECD (known as the mandatory disclosure rules, or MDR) will enter into force in the UK on 28 March 2023. Arrangements entered into on or after this date must be reported to HMRC under this regime.
MDR: ICAEW concerned over backdated reporting
  • Article
  • 09 Feb 2022
ICAEW’s Tax Faculty welcomes that the new rules designed to implement the OECD’s model mandatory disclosure regime are targeted at those arrangements that might allow or facilitate tax evasion. However, it has concerns over the backdated reporting requirements, which exceed those of the predecessor DAC 6 legislation.
HMRC expands reporting portal for mandatory disclosure rules
  • Article
  • 16 Mar 2021
It is now possible to manually report arrangements between the UK and EU member states under the mandatory disclosure reporting regime (commonly known as DAC 6).
Final call for first UK DAC 6 reporting deadline
  • Article
  • 27 Jan 2021
27 January 2021: The first reports under the UK’s mandatory disclosure regime, based on the EU’s DAC 6, are due on 30 January 2021. ICAEW’s Tax Faculty provides a reminder of the rules.
DAC 6 to be replaced by OECD rules for UK intermediaries from 2021
  • Article
  • 31 Dec 2020
4 January 2021: HMRC has confirmed that the UK will no longer be applying DAC 6 in its entirety following conclusion of the Free Trade Agreement with the EU. Only arrangements that would have fallen within Category D of DAC 6 will now need to be reported, in line with the OECD’s mandatory disclosure rules.
Red flags to navigate DAC 6 hallmarks
  • Article
  • 15 Dec 2020
15 December 2020: With the first reporting deadline less than two months away, Simon Bird from BDO LLP talks through a risk-based approach to compliance with DAC 6, highlighting practical ways in which entities can recognise the classes of arrangements which might be subject to these rules.

Recordings

DAC6 the OECD Mandatory Disclosure Regimes in brief
  • Webinar
  • 15 Feb 2021
An introduction to DAC6 and the OECD Mandatory Disclosure Regimes in the context of UK reporting.
Exclusive The UK and DAC6 post-Brexit - where are we now?
  • Webinar
  • 19 Jan 2021
In this webinar ICAEW Tax Faculty Business Tax Manager, Richard Jones, is joined by Jo Myers and Ariana Kosyan of EY to get you up to speed with the current position and discover the likely future shape of disclosure requirements for UK advisers and their clients.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising more than 60 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.
Exclusive IFRS 6 - Exploration for and evaluation of mineral resources
  • eBook chapter
  • 2022
  • HMRC
A section on the scope of IFRS 6 and its use in oil industry accounting, looking at recognition of exploration and evaluation assets, measurement at recognition, elements of cost of exploration and evaluation assets, measurement after recognition, reclassification of exploration and evaluation assets and impairment.
Exclusive EU DAC 6 - the EU Mandatory Disclosure regime
  • eBook chapter
  • 2021
  • John Hiddleston, Azets
  • Automatic Exchange of Information Handbook
A chapter giving an overview of the EU Directive on Mandatory Disclosure rules, 'DAC 6', in this practical guide to the automatic exchange of information rules legislation within the UK.
Exclusive EU DAC 6 - Who must report?
  • eBook chapter
  • 2021
  • John Hiddleston, Azets
  • Automatic Exchange of Information Handbook
A chapter giving an overview of the EU Directive on Mandatory Disclosure ('DAC 6') reporting rules, in this practical guide to the automatic exchange of information rules legislation within the UK.
Exclusive DAC 6
  • eBook chapter
  • 2021
  • Julian Hickey, Adrian Shipwright
  • Law and Regulation of Tax Professionals
A chapter covering the law and associated practical matters concerning DAC 6 compliance for tax professionals.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.

External resources

Some resources that we link to may pre-date the latest amendments to the relevant tax regulations. While these links contain useful information, please treat them with appropriate caution.

Check if you need to tell HMRC about a cross-border arrangement
  • Website
  • 29 Oct 2020
Guidance on reportable cross-border arrangements (DAC6) involving the UK and an EU member state. It covers what arrangements need to be reported, who needs to report, when they must inform HMRC, and how to register and report.
Administrative cooperation in the field of taxation: Summary of EU Directive 2011/16
  • Website
  • 26 Oct 2020
Official summary of DAC6 with key points highlighting the scope and requirements of the Directive. It includes links to the legislation and amendments.
DAC6: Disclosure of cross-border arrangements research
  • Website
  • 25 Aug 2020
Research report on the involvement of UK intermediaries in cross-border tax arrangements and potential impact of DAC6 regulations. The research surveyed accountants, tax advisors, lawyers, wealth managers and banks.
Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
  • Website
  • 09 Mar 2018
This report presents the text of the OECD model rules, alongside an overview of key elements and commentary on definitions, disclosure requirements and penalties.
OECD Mandatory Disclosure Rules
  • Website
  • 05 Oct 2015
The report gives an overview of mandatory disclosure regimes in different jurisdictions and sets out a modular framework for countries implementing mandatory discloure rules, with specific recommendations for rules targeting international tax schemes.

ICAEW accepts no responsibility for the content on any site to which a hypertext link from this site exists. The links are provided ‘as is’ with no warranty, express or implied, for the information provided within them. Please see the full copyright and disclaimer notice.

Further support

TAXconnect
  • Listing
  • 06 Mar 2015
Search for a consultant to help you with a specific technical tax problem. TAXconnect works on a telephone ‘hotline’ system, whereby consultants offer advice to fellow Tax Faculty members and Faculties Online subscribers on tax problems for a nominal fee.
Tax Faculty Find out more about the Tax Faculty and upcoming events. Faculty members can access exclusive content, including TAXline, TAXguides, webinars, representations and support schemes.
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